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IN THE COURT OF COMMON PLEAS
OFCUMBERLANDCOUNTY
STATE OF
PENNA.
ROBERT C. HOUSER, JR"
Plaintiff
No. 00-5857 CIVIL
VERSUS
CHRISTINE H. HOUSER,
Defendant
DECREE IN
DIVORCE
AND NOW,
7)~
19
, IT IS ORDERED AND
, 2doo
DECREED THAT
ROBERT C. HOUSER, JR.
, PLAINTIFF,
AND
CHRISTINE H. HOUSER
, DEFENDANT,
ARE DIVORCED FROM THE BONDS OF MATRIMONY.
THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE
BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT
YET BEEN ENTERED;
None
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WA'mEF.SHADE
Attorney ~t Law
53 West Pomfret Street
Carlisle, PemtSY1vania
17013
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ROBERT C. HOUSER, JR.,
Plaintiff
: IN TIlE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYL VANIA
: CIVIL ACTION - LAW
v.
: NO. 00-5857 CIVIL TERM
CHRISTINE H. HOUSER,
Defendant
: IN DIVORCE
PRAECIPE TO TRANSMIT RECORD
To the Prothonotary:
Please transmit the record, together with the following information, to the Court
for entry of a divorce decree:
L Ground for divorce: Irretrievable breakdown under 3301(c) of the Divorce
Code,
2. The date and manner of service ofthe Complaint were August 26, 2000, by
United States certified mail, return receipt requested, addressee only.
3. Date of execution of the Affidavit of Consent and Waiver of Notice of Intention
to Request Entry ofa Divorce Decree under ~3301(c) of the Divorce Code by Plaintiff
was November 27,2000, and by Defendant was November 27,2000.
4. Related claims pending: None,
Date: December 15, 2000
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Wayn F. Shade
Attorney for Plaintiff
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ROBERT C. HOUSER, JR.,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYL VANIA
: CIVIL ACTION - LAW
v.
: NO. 00-
CIVIL TERM
CHRISTINE H. HOUSER,
Defendant
: IN DIVORCE .
NOTICE TO DEFEND AND CLAIM RIGHTS
You have been sued in Court. If you wish to defend against the claims set forth in the
following pages, you must take prompt action. You are warned that if you fail to do so, the case
may proceed without you, and a decree of divorce or annulment may be entered against you by
the Court. A judgment rnay also be entered against you for any other claim or relief requested in
these papers by the Plaintiff. You may lose money or property or other rights important to you,
including custody or visitation of your children.
When the ground for the divorce is indignities or irretrievable breakdown ofthe marriage,
you may request marriage counseling. A list of marriage counselors is available in the Office of
the Prothonotary at
CUMBERLAND COUNTY COURTHOUSE. CARLISLE. PENNSYLVANIA 17013
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY,
LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED,
YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM.
YOU SHOULD TAKE TillS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO
NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE
OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
Cwnberland County Bar Association
2 Liberty Avenue
Carlisle, Permsylvania 17013
Telephone: 717-249-3166
WAYNEF. SHADE
Attorney at Law
53 West Pomfr~t Street
Carlisle, Pennsylvania
17013
A hearing on the issue of alimony pendente lite advanced in the within Complaint is
demanded, ?(; ~
Wayn~de, Esquire
Supreme Court No. 15712
53 West Pomfret Street
Carlisle, Permsylvania 17013
Telephone: -717-243-0220
Attorney for Plaintiff
WAYNE F. SilADE
Attorney at Law
53 West Pomfret Street
Carlisle, Pennsylvania
17013
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ROBERT C. HOUSER, JR.,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYL VANIA
: CIVIL ACTION - LAW
v,
: NO. 00-5?S1CIVIL TERM
CHRISTINE H. HOUSER,
Defendant
: IN DIVORCE
COMPLAINT
COUNT I
DIVORCE
L
Plaintiff in this Action in Divorce is ROBERT C, HOUSER, JR., an adult
individual who resides at 1103 Holly Pike, Carlisle, Cumberland County, Pennsylvania
17013.
2.
Defendant is CHRISTINE H. HOUSER, an adult individual and citizen of the
,
United States of America who resides at 7 Persimmon Drive, Boiling Springs (South
Middleton Township), Cumberland County, Pennsylvania 17007.
3.
Defendant has been a bona fide resident of Cumberland County, Pennsylvania, for
more than six months previously to the filing of this Complaint and continuing to the
commencement of this Action in Divorce.
,
WAYNEF.SHADE
Attorney at Law
53 WestPomfret Street
Carlisle, Petm$ylvania
17013
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4.
Plaintiff and Defendant were lawfully joined in marriage on June 21, 1975, at
Carlisle, Cumberland County, Pennsylvania.
5.
The parties have been living separate and apart since August 14,2000.
6.
Plaintiff avers as the grounds on which this action is based that Defendant has
offered such indignities to the person of the Plaintiff, the innocent and injured spouse, as
to render the condition of Plaintiff intolerable and the life of Plaintiff burdensome. In the
alternative, Plaintiff avers as the grounds on which this action is based that the marriage
of the parties is irretrievably broken.
7.
There have been no prior actions for divorce or annulment of this marriage in
Pennsylvania or in any other jurisdiction.
8.
This Action in Divorce is not collusive,
9.
Both parties to this Action in Divorce are legally capable of managing their own
concerns.
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Defendant herein is not a member of the armed forces of the United States of
America.
11.
There were two children born to the parties, neither of whom is a minor or
otherwise dependent.
12.
Plaintiff has no adequate means of support for himself,
13.
Plaintiff has been advised that counseling is available and that Plaintiff may have
the right to request that the Court require the parties to participate in counseling.
WHEREFORE, Plaintiff demands judgment dissolving the marriage between the
parties.
COUNT II
EQUITABLE DISTRIBUTION
14.
The averments of Paragraphs 1 through 13 inclusive above are incorporated herein
by reference as though fully set forth.
15.
Plaintiff and Defendant possess various items of marital property which are subject
WAYNEF. SHADE to equitable distribution by the Court.
Attorney at Law
53 West Pomfret Street
Carlisle, Pennsylvania
17013
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WAYNEF. SHADE
Attorney at Law
53 West Pomfret Street
Carlisle, Pennsylvania
17013
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WHEREFORE, Plaintiff demands judgment equitably distributing all marital
property owned by the parties and such further relief as the Court may deem equitable and
just.
COUNT III
ALIMONY AND ALIMONY PENDENTE LITE
16.
_ The averments of Paragraphs 1 through 13 inclusive above are incorporated herein
by reference as though fully set forth,
WHEREFORE, Plaintiff demands judgment compelling Defendant to pay to
Plaintiff alimony and alimony pendente lite.
COUNT IV
COUNSEL FEES, EXPENSES AND COSTS
17.
The averments of Paragraphs 1 through 13 inclusive above are incorporated herein
by reference as though fully set forth.
_ WHEREFORE, Plaintiff demands judgment compelling Defendant to pay counsel
fees, expenses and costs of Plaintiff.
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Way F. Shade, Esquire
Supreme Court No. 15712
53 West Pomfret Street
Carlisle, Pennsylvania 17013
Telephone: 717-243-0220
Attorney for Plaintiff
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WAYNEF.SHADE
Attorney at Law
53 WestPornfret Street
Carlisle, PelInsylvania
17013
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I verifY that the statements made in this pleading are true and correct I understand
that false statements herein are made subject to the penalties of 18 Pa.C.S, ~4904 relating
to unsworn falsification to authorities.
Date: August 24, 2000
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Robert C. Houser, Jr.
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WAYNEF, SHADE
Attorney at Law
53 WestPomfret Street
Carlisle, Pennsylvania
17013
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ROBERT C. HOUSER, JR.,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYL VANIA
: CIVIL ACTION - LAW
v.
: NO. 00-5857 CIVIL TERM
CHRISTINE H. HOUSER,
Defendant
: IN DIVORCE
AFFIDAVIT OF CONSENT AND WAIVER OF NOTICE
OF INTENTION TO REQUEST ENTRY OF A
DIVORCE DECREE UNDER g3301(c)
OF THE DIVORCE CODE
COMMONWEALTH OF PENNSYL VANIA)
) SS:
COl)NTY OF CUMBERLAND )
I.
A Complaint in Divorce under ~3301(c) of the Divorce Code with Notice of
Availability of Counseling was filed on August 25, 2000, and served on August 25, 2000.
2.
The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90)
days have elapsed from the date of filing and service of the Complaint.
3.
I consent to the entry of a Final Decree of Divorce without notice.
4.
I understand that I may lose rights concerning alimony, division of property,
lawyer's fees or expenses if I do not claim them before a divorce is granted.
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WAYNEF.SHADE
Attorney at Law
53 West Pomfret Street
Carlisle, Pennsylvania
17013
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I understand that I will not be divorced until a Divorce Decree is entered by the
Court and that a copy of the Decree will be sent to me immediately after it is filed with
the Prothonotary.
6.
I have been advised oftheavailability of marriage counseling and of my right to
counseling and understand that I may request that the Court require that my spouse and I
participate in counseling.
7.
I understand that the Court maintains a list of marriage counselors in the Domestic
Relations Office, which list is available to me upon request.
8.
Being so advised, I do not request that the Court require that my spouse and I
participate in counseling prior to a Divorce Decree's being handed down by the Court.
9.
I veritY that the statements made in this Affidavit are true and correct. I
understand that false statements herein are made subject to the penalties of 18 Pa.C.S.
~4904 relating to unsworn falsification to authorities.
Date: November 27,2000
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Robert C. Houser, Jr.
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ROBERT C. HOUSER, JR.,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYL VANIA
: CIVIL ACTION - LAW
v.
: NO. 00-5857 CIVIL TERM
CHRISTINE H. HOUSER,
Defendant
: IN DIVORCE
AFFIDAVIT OF CONSENT AND WAIVER OF NOTICE
OF INTENTION TO REQUEST ENTRY OF A
DIVORCE DECREE UNDER g3301(c)
OF THE DIVORCE CODE
COMMONWEALTH OF PENNSYLVANIA )
) SS:
COUNTY OF CUMBERLAND )
I.
A Complaint in Divorce under ~3301(c) of the Divorce Code with Notice of
Availability of Counseling was filed on August 25, 2000, and served on August 25, 2000.
2.
The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90)
days have elapsed from the date of filing and service of the Complaint.
3.
I consent to the entry of a Final Decree of Divorce without notice.
4.
I understand that I may lose rights concerning alimony, division of property,
lawyer's fees or expenses in do not claim them before a divorce is granted.
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I understand that I will not be divorced until a Divorce Decree is entered by the
Court and that a copy of the Decree will be sent to me immediately after it is filed with
the Prothonotary.
6.
I have been advised of the availability of marriage counseling and of my right to
counseling and understand that I may request that the Court require that my spouse and I
participate in counseling.
7.
I understand that the Court maintains a list of marriage counselors in the Domestic
Relations Office, which list is available to me upon request.
8.
Being so advised, I do not request that the Court require that my spouse and I
participate in counseling prior to a Divorce Decree's being handed down by the Court.
9.
I veritY that the statements made in this Affidavit are true and correct. I
understand that false statements herein are made subject to the penalties of 18 Pa.C.S.
~4904 relating to unsworn falsification to authorities.
Date: November 27,2000
r!hrt~ )), ~r
Christine H. Houser
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WAYNEF, SHADE
Attorney at Law
53 West Pomfret Street
Carlisle, Pennsylvania
17013
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ROBERT C. HOUSER, JR.,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYL VANIA
: CIVIL ACTION - LAW
v.
: NO. 00-5857 CIVIL TERM
CHRISTINE H. HOUSER,
Defendant
: IN DIVORCE
AFFIDAVIT OF SERVICE
WAYNE F. SHADE, ESQUIRE, certifies that he is counsel for Plaintiff in the
abo"e-captioned matter, that he did, on August 25, 2000, serve the Complaint in Divorce
in the above-captioned matter upon Defendant by certified United States mail, postage
prepaid, return receipt requested, addressee only, and that the same was received by
Defendant on August 26, 2000, as evidenced by the return receipt card attached hereto
bearing Certified No. Z 013349 179. It is understood that false statements herein are
made subject to the penalties of 18 Pa.C.S. ~4904 relating to unsworn falsification to
authorities.
Date: August 29,2000
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Wayn . Shade
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I also wish to receive the
following services (for an
extra fee):
1. 0 Addressee's Address
........
Consult postmaster for fee.
4a. Article Number
Z 013 349 179
4b. Service Type
o Registered
o Express Mail
o Retum Receipt for Merchandise
7. Date of Delivery
6-2&00
8. Addressee's Address (Only if requested
and fee is paid)
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Z 013 349 179
US Postal Service
Receipt for Certified Mail
No Insurance Coverage Provided.
00 not use for International Mail (See reverse)
Sentto
Christine H. Houser
Street & Number
7 Persimmon Drive
Post Office, State, & ZIP Code 17 07
Boi1in" Sorin2:s PA
Postage $ .77
Certified Fee 1. 40
Special Delivery Fee
Resbicted De~very Fee 2.75
Return Receipt Showing to 1. 25
Whom & Date Delivered
is. RetumReceiplIll1owi\JIoWhom,!
. DIIIe,&Addressee.Address
TOTAL Postage & Fees $ 6.17
Postmark or Date
E
Ji August 25, 2000
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<;; SENDER:
"C . Complete items 1 and/or 2 for additional services.
oiii . Complete items 3, 4a, and 4b.
Q,l . Print your name and address on the reverse of this form so, that we can return this
f card to you.
Q,l . Attach this form to the front of the mailpiece, or on the back if space does not
~ penna.
. Write "Retum Receipt Requested" on the mailpiece below the article number.
~ . The Return Receipt will show to w'1iom the article was delivered and the date
+- delivered.
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3. Article Addressed to:
Ms. Christine H. Houser
7 Persimmon Drive
Boiling Springs, PA 17007
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.!!! PS Form 3811, December 1994
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ROBERT C. HOUSER, JR.,
Plaintiff/Petitioner
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
VS.
CIVIL ACTION - DIVORCE
CHRISTINE H. HOUSER
DefendantlRespondent
NO. 00-5857 CIVIL TERM
IN DIVORCE
DR# 30,035
PacseS# 082102642
ORDER OF COURT
AND NOW. this 25th day of September. 2000, upon consideration of the attached Petition for
Alimony Pendente Lite and/or counsel fees. it is hereby directed that the parties and their respective
counsel appear before RJ. Shaddav on October 18. 2000 at 9:00 A.M. for a conference. at 13 N" Hanover
St., Carlisle, PA 17013, after which the conference officer may recommend that an Order for Alimony
Pendente Lite be entered,
YOU are further ordered to bring to the conference:
(I) a true copy of your most recent Federal Income Tax Return, including W-2's as filed
(2) your pay stubs for the preceding six (6) months
(3) the Income and Expense Statement altached to this order, completed as required by Rule
19I0.IW
(4) verification of child care expenses
(5) proof of medical coverage which yon may have, or may have available to you
IF yon fail to appear for the conference or bring the required documents, the Court may issue a
warrant for your arrest.
BY THE COURT,
George E, Hoffer, President Judge
Ml!!l qQ~i~s on
.. tjiZY;()Oto:
Petitioner
< Respondent
Wayne Shade. Esquire
j} . ;JL
R J hadday, Conference Officer
Date of Order: September 25, 2000
YOU HAVE THE RIGHT TO A LAWYER, WHO MAY ATTEND THE CONFERENCE AND
REPRESENT YOU. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO
OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU MAY GET
LEGAL HELP.
CUMBERLAND COUNTY BAR ASSOCIA nON
2 LIBERTY AVE,
CARLISLE, PENNSYLVANIA 17013
(717) 249-3166
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ROBERT Co HOUSER, JR.,
PlaintiffJPetitioner
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
VS.
CIVIL ACTION. DIVORCE
CHRISTINE H. HOUSER
Defendant/Respondent
NO. 00.5857 CIVIL TERM
IN DIVORCE
DR# 30,035
PacseS# 082102642
ORDER OF COURT
AND NOW, this 25th day of September, 2000. upon consideration of the attached Petitiou for
Alimony Peudente Lite and/or cOlmsel fees, it is hereby directed that the parties and their respective
counsel appear before R.J. Shaddav on October 18. 2000 at 9:00 A.M. for a conference. at 13 N, Hanover
St., Carlisle, P A 17013, after which the conference officer may recommend that an Order for Alimony
Pendente Lite be entered.
YOU are further ordered to bring to the conference:
(I) a true copy of your most recent Federal Income Tax Return, including W.2's as filed
(2) your pay stubs for the preceding six (6) months
(3) the Income and Expense Statement attached to this order. completed as required by RuIe
19mUi{)
(4) verification of child care expenses
(5) proof of medical coverage which you may have. or may have available to you
IF you fail to appear for the conference or bring the required documents, the Court may issue a
warrant for your arrest.
BY THE COURT.
George R Hoffer, President Judge
Mail copieS on
9,,~~~ltl>\
Petitioner
< Respondent
Wayne Shade, Esquire --r1
Date of Order: September 25. 2000 f~ R.' y, Conference Offic"
yOU HAVE THE RIGHT TO A LAWYER, WHO MAY ATTEND THE CONFERENCE AND
REPRESENT YOU. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO
OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU MAY GET
LEGAL HELP.
CUMBERLAND COUNTY BAR ASSOCIATION
2 LIBERTY AVE.
CARLISLE, PENNSYLVANIA 17013
(717) 249.3166
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